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U.S. v. Furkin, No. 95-3911 (7th Cir.) (119 F.3d 1276) (July 14, 1997) (Judge William J. Bauer)

In approving the use of a sophisticated means enhancement under § 2T1.1(b)(2), the court agreed that "there is a certain amount of overlap among various factors as they relate to sophisticated means, obstruction of justice, departure, as well as the guideline for the underlying conspiracy. However, as the Government …

 

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